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Submitted URL: https://nkq14ldx.r.eu-west-1.awstrack.me/L0/https:%2F%2Fenroll.krollmonitoring.co.uk%2Fredeem/1/020200009vssmi4l-qlss0vvk-ul9h-qecd-blak-...
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CONSENT

UK PRIVACY POLICY



Last Revision Date: [28/05/2021]

1.Who we are

We are Kroll Information (UK) Ltd. (referenced further as “Kroll”, “we”, “us”
and “our”) and can be contacted with questions, concerns, or complaints using
the following details:

Kroll Information (UK) Ltd.
The Shard, 32 London Bridge Street
London, SE1 9SG
dp.privacy@kroll.com



Data Protection Officer: Daniela Mosca

 * Email: daniela.mosca@kroll.com
 * Telephone: +39.039.64.23.812
 * Post: Daniela Mosca at Kroll REAG SpA, Centro Direzionale Colleoni, Palazzo
   Cassiopea 3, 7th Floor, Via Paracelso 26, 20864 Agrate Brianza (MB) - Italy

We respect individual privacy and value the confidence of our subscribers. This
Privacy Policy sets out the privacy principles that we follow with respect to
processing personal data in the course of providing our products and services
(“Services”) in the United Kingdom (UK) via our web portal (“Portal”). The
Services and Portal, together with any related online or electronic
documentation found in the Portal, are collectively referred to within this
Privacy Policy as the “Platform”.

Kroll is registered with the Financial Conduct Authority (FCA) and has
maintained a status of Authorised since 14/01/2019. Kroll’s Registered Company
Number is 11500987.

Subsidiary, affiliate, partner and third-party websites

This Privacy Policy applies to all personal data provided to, or collected by,
Kroll from subscribers applying to use and using our services via the Portal. To
the extent that this Platform permits you to link to or otherwise access the
websites of Kroll's subsidiaries, affiliates, partners, or other third-parties,
separate privacy policies may apply to those linked websites. Those separate
privacy policies may contain terms different than those contained in this
Privacy Policy, and your access to and use of such linked websites are not
governed by this Privacy Policy. Kroll expressly disclaims any and all
responsibility for your access to and use of such linked websites, as well as
for any use of the information that you may provide, or any information that may
be collected about you, at such linked websites.

2. Information collected about you

a. Personal data you provide to us or our agents
During enrolment, or in order to provide a product or service, we or our agents
may collect personal data about you, such as:

 * name, address, phone number, and e-mail address
 * date of birth, driver's licence number, passport number, national insurance
   number and other similar information
 * copies of government-issued photo identification and/or utility bill(s),
   where applicable
 * credit card number and other financial account data such as your bank account
   details, your debit card details, your NHS number and store or loyalty card
   details
 * your responses to security questions
 * the information you provide in customer service contact or correspondence
 * When you talk to us: for example on the phone, or in person including call
   recordings and voice messages. We may monitor or record calls with you to
   check we have carried out your instructions, to resolve queries or disputes,
   to improve the quality of our service or for regulatory or fraud prevention
   purposes
 * In writing: for example letters, proposal forms, survey responses, emails,
   chat messages and texts.

b. Information which may be collected automatically including when you use our
services

 * Transaction data: for example when we deal with or manage your account;
 * Online: for example when you use our Portal;
 * Electronically: for example when you use our Portal;
 * Usage and profile data: for example, from your use of our Portal. We gather
   this data using cookies and other software which also helps us to fix bugs or
   crashes on the operating system or network.

The Portal, online services, applications, email messages, and advertisements,
if any, may use cookies and other technologies such as pixel tags and web
beacons to collect information about you and your activity (pixel tags and web
beacons are also known as clear GIFs, action tags or web tags), such as your IP
address, operating system, browser type, and service provider, and website
session statistics. For more information, see the Information Collected from
Cookies and Other Technologies section below. Please see our Cookies Policy for
further information.

3. Purpose and legal basis of collection

We will only use your personal data when the law allows us to do so. Most
commonly we will use your personal data in the following circumstances:

 * where you have consented before the processing;
 * where we need to perform a contract we have entered into with you;
 * where it is necessary for our legitimate interests (or those of a third
   party) and your interests and fundamental rights do not override those
   interests;
 * where we need to comply with a legal duty or regulatory obligation (legal
   duty).

Purpose/activity

Type of Data

Lawful basis for processing

To register you as a user of the Platform

Identity
Contact Details
Financial
Device

Performance of a contract with you
Legal duty
Consent
Legitimate interests (verifying identity, maintaining up to date records,
business efficiency, risk management, product development)

To deliver the Services to you (defined below)
customer service account management to manage payments, fees and charges to
collect and recover money owed to us

Identity
Contact
Financial
Transaction
Location

Performance of a contract with you
Necessary for our legitimate interests (risk management, product development,
business efficiency)
Legal duty

To manage our relationship with you including notifying you of changes to the
Portal or Privacy Policy or other relevant terms and conditions

Identity
Contact
Financial
Profile
Communications

Performance of a contract with you
Necessary for our legitimate interests (risk management, product development,
business efficiency)
Legal duty

To administer and protect you and us and the Portal (include troubleshooting,
data analysis, testing, system maintenance, support, reporting and hosting of
data)

Identity
Contact
Device/Technical

Necessary for our legitimate interests (for running our business, provision of
administration and IT services, network security, business efficiency)
Performance of a contract with you

To measure and analyse the effectiveness of the Services (defined below)
including the use of data analytics

To monitor trends so we can improve the Platform

Contact Details
Device
Usage
Location



Necessary for our legitimate interests (to develop our Services and grow our
business).


We and our agents will use the personal data provided by you to provide our
identity monitoring, consultation, and restoration services (“Services”).

We and our agents will also use the information you provide to us or that we
collect automatically for the purpose of providing you with the Services and for
administering our relationship with you, for internal business purposes, for our
product or service development and/or statistical analysis. This includes
verification of your identity and address.

When you close your account, we will continue to store and may use and share the
collected information in accordance with this Privacy Policy and our legal and
regulatory requirements. We will retain the information as long as necessary to
fulfil the purposes for which it was provided, plus any reasonable length of
time that is necessary to fulfil our legal, regulatory, and reasonable business
purposes.

From time to time we may contact you to ask for your consent to use your
personal data for other purposes. Your personal data may also be used for other
purposes where required or permitted by law.

In connection with the provision of the Services, we may provide your
information to our partners, third parties and customer service agencies for
research and analysis purposes so that we can monitor and improve the services
we provide. We may contact you by post, e-mail or telephone (or as required) to
ask you for your feedback and comments on our services (or as the case may be).
Contact us if you require further information as to the identities of these
organisations.

From time to time we may contact you about goods or services that may be of
interest to you.

4. Disclosure of personal data to third parties

Kroll may share personal data collected from you with third parties as necessary
to provide the Services you have requested.

In order for us to provide you with our Services, Kroll and/or its agents may
share your personal data with its affiliated companies, with third party service
providers retained by Kroll to provide services on its behalf (such as call
handling, administration, mailing services, account management, data hosting,
marketing, analytics, identity monitoring, and customer service) or with others,
with which you have a relationship (for instance to discuss an issue you have
with your account) or as required by law, legal process, and/or regulation.

In the event that you receive Credit Monitoring Services (as defined in the End
User Agreement), Kroll will need to share personal data collected from you with
TransUnion for the following purposes: (i) in order to provide Credit Monitoring
Services, (ii) to assist TransUnion with identity verification and prevention of
fraud/money laundering, and (iii) any other uses that may be mutually agreed
upon by us and TransUnion from time to time. Such personal data will be
processed by TransUnion in accordance with TransUnion’s Privacy Notice, which is
available https://transunion.co.uk/legal-information/bureau-privacy-notice/
(“TransUnion Privacy Notice”). References to "TransUnion" in this Privacy Policy
mean TransUnion International UK Limited (company number 3961870), a credit
reference agency authorised and regulated by the Financial Conduct Authority
under number 737740, whose registered office is at One Park Lane, West
Yorkshire, LS3 1EP. Authorisation can be checked on the Financial Services
Register at www.fca.org.uk.

We require all affiliated companies and third party service providers to protect
the security of your personal data and only use it to accomplish the purposes
for which the personal data was collected. All affiliated companies are subject
to applicable data protection laws.

Your personal data may also be shared under the following circumstances: (i) if
Kroll is legally required to do so or is required to do so by any legal or
regulatory authority; and (ii) in connection with investigations, or other
efforts to prevent illegal, fraudulent or criminal activities or pertaining to
public safety.

In addition, in the event of a merger, acquisition, or any form of sale of some
or all of our assets to a third party, we may also disclose your personal data
to the third parties concerned or their professional advisors. In the event of
such a transaction, the personal data held by Kroll will be among the assets
transferred to the buyer.

We may share aggregate, non-personal and/or de-identified data with third
parties, to the extent permitted by law.

5. When personal data is transferred outside the European Economic Area (EEA)

We currently share personal data with our office in the United States of America
(USA) under a contract containing the EU model contract clauses as prescribed by
the European Commission. Our USA office will comply with any provisions put in
place by the UK Government following Brexit to protect the exchange of personal
data between the UK and the USA

6. Consequences

If we determine that you pose a fraud or money laundering risk, we may refuse to
provide the Services to you or we may stop providing existing Services to you.
We may also suspend or terminate any access you have to our Portal. A record of
any fraud or money laundering risk will be retained by the fraud prevention
agencies, and may result in others refusing to provide services, financing or
employment to you.

If you fail to provide us with data we require, this may delay or prevent us
from entering into a contract with you, delay your access to the Portal and/or
prevent us from providing the Services to you.

If you have any questions about the above, please contact us on the details in
section 1 above.

7. What choices and rights you have

Your personal data is protected by legal rights, which include your right to:

 * object to our controlling and processing your personal data;
 * object to our sharing of your personal data with others or with certain
   organisations;
 * request that your personal data is erased or corrected or that its processing
   be restricted;
 * request access to your personal data and for it to be given to you in a
   portable format;
 * request that we transfer your personal data to another service provider;
 * request that we confirm what personal data we currently control and/or
   process in relation to you.

For more information or to exercise your data protection rights please, please
contact us using the contact details given above.

There may be reasons why we need to keep or use your data, but please tell us if
you think we should not be processing your data.

If you are unhappy about how your personal data has been used by us please
contact us and we will send you our Complaints Policy. You also have a right to
complain to the Information Commissioner's Office which regulates the processing
of personal data. You can contact them at Information Commissioner's Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, on 0303 123 1113 or by
email to casework@ico.org.uk. See also https://ico.org.uk/global/contact-us/.

8. How long personal data is kept

We will retain your personal data for as long as you are a subscriber to our
Services or whilst you continue to use the Portal. We may retain your personal
data beyond this date for the purposes mentioned above and will in any case at
all times retain your personal data for the minimum period required by law. We
may also retain your data to deal with any disputes, to maintain records and to
show we have dealt with you fairly.

We may also retain your aggregated or de-personalised data for research and
statistical purposes in which case we will ensure it is kept private and used
only for these purposes.

9. Changes to this Privacy Policy

Kroll reserves the right, in its sole discretion, to make changes to this
Privacy Policy. When changes are made to the Privacy Policy, the Last Revision
Date field at the top of the Privacy Policy will be updated accordingly. Changes
to the Privacy Policy become effective upon posting and updating the Last
Revision Date. Kroll encourages you to periodically review the Privacy Policy to
be informed of any changes.

10. Children

Kroll does not knowingly collect information from children under the age of 13
(or applicable age of consent if higher in other countries) and does not target
its websites to children under 13 (or applicable age of consent if higher in
other countries). Kroll encourages parents and guardians to take an active role
in their children's online activities and interests. If Kroll learns that a
child under the age of 13 (or such legally required higher age) has submitted
personal data online without parental consent, we will take all reasonable steps
to delete such information from our databases and not to use such information
for any purpose (except where necessary to protect the safety of the child or
others as required or as allowed by law). If you become aware of any personal
data we have collected from children under 13 (or such legally required higher
age), please contact us using the contact details given above.

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Kroll provides identity monitoring services to help individuals monitor for
indicators of potential fraud or identity theft.
We are proud to have been offered as a resource to help millions of individuals
recover from fraud and identity theft.
Before we can begin monitoring your identity, you will need to create an account
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© 2023 Kroll Information (UK) Ltd.

Kroll is registered with the Financial Conduct Authority (FCA) and has
maintained a status of Authorised since 14/01/2019. Kroll’s Registered Company
Number is 11500987.



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